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Attachment 2A U.S.ENVIRONMENTAL PROTECTION AGENCY +. SUMMARY OF SPCC DEFICIENCIES Onshore Facilities(Excluding drilling,production and workover) Facility Name/Address: �',7ZZX7C'✓t,KLA Facility Start Dated c 1<_-/" inspector: ti /iZ-lr Date: :5L.LA Y SPCC#: Citation Deficiency Plan Field 112.3(a) No Spill Prevention Control and Countermeasures Plan 112.3(d); Plan not certified by a Professional Engineer(PE),not self-certified,or incomplete 112.6(a)(1)or(b)(1) 112.3(e)(1)or(2) Plan not maintained on site or not available for review I IZ3(g) Plan self-certified(or Tier I template used)though not eligible 112.5(a) No plan amendment(s)after change In:design,construction, operation,or maintenance 112.5(b) No evidence of five year review of plan by owner/operator 112.5(c); Technical amendments(s)not certified by a PE or self-certified 112.6(a)(2)or(b)(2) 112.6(b)(2) PE certified portions of Plan not certified by a PE following technical amendments 112.6(b)(3) Deviations from the SPCC rule requirements are not certified by a PE 112.7 No signed management approval of plan 112.7 Plan does not follow sequence or have a cross reference 112.7(a)(2) No or inadequate environmental equivalent for deviations from requirements 112.7(a)(3) No or incomplete facility diagram - - -_-- 112.7(a)(3)(i) No or incomplete listing of type of oil and storage capacity of containers 112.7(a)(3)(h) No or inadequate description of discharge prevention measures 112-7(a)(3)(iii) No or inadequate description of drainage controls 112.7(a)(3)(iv) Notinadequate description of countermeasures for discharge discovery,response,cleanup 112.7(a)(3)(v) No or inadequate description of disposal methods for recovered materials 112.7(a)(3)(vi) No inoomple contact list&phone numbers for response&reporting discharges 112.7(a)(4) No or inadequate procedures for reporting discharges 112.7(x)(5) No or inadequate procedures for use in an emergency 112.7(b)or Plan has inadequate or no prediction of 112.6(a)(3)(i) equipment failure which could result in discharges 112.7(c) No adequate oontainment and/or diversionary strictures to prevent a discharge3�1,a 1 r 112.7(d) No or inadequate demonstration that secondary containment is impracticable 112.7(d) No periodic integrity and leak testing of containers,valves and piping when impracticability is claimed for bulk storage containers 112.7(d)(1) No or inadequate:contingency plan per 40 CFR part 109 or FRP under 112.20 112.7(d)(2) No written commitment of manpower,equipment,and materials 112.7(e) Inspections and tests not in accordance with written procedures in Plan 112.7(e) Record of inspections are not signed by facility supervisor 112.7(e) Record of inspections are not maintained for three years 112.7(0(1) No training of oil-handling personnel on discharge prevention 112.70(2) No designated person responsible for soil prevention 112.7(0(3) Spill prevention briefings are not conducted at least annually �(°) itF? C'C x 112.7(g) No or inadequate description of facility security 112.7(h)(1) Loadinq/unloading rack drainage does not flow to containment 112.7(h)(1) Containment system does not hold at least the maximum capacity of the largest single compartment of any tank car or tank tnxdk using the rack 112.7(h)(2) No interlocked warning light,physical barrier system,or warning signs to prevent vehicular departure before complete disconnect from transfer lines Deficiencies found during the inspection are marked with an"X"